Law Offices of Swati M. Kothari, LLC Swati M. Kothari, Esq ...€¦ · Swati M. Kothari, Esq. 712 East Main Street, Suite 2A Moorestown, New Jersey 08057 (856) 359-6699 Attorneys

!!Law Offices of Swati M. Kothari, LLC Swati M. Kothari, Esq. 712 East Main Street, Suite 2A Moorestown, New Jersey 08057 (856) 359-6699 Attorneys for Plaintiff !!

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY

CAMDEN VICINAGE _______________________________________________________________________________ : SAFET HAJRA, :

: Plaintiff, : Civil Action No. : vs. : : COMPLAINT AND WAWA INC. : JURY DEMAND : Defendants. : : _______________________________________________________________________________ !

INTRODUCTION

1. This is an action for declaratory, injunctive and equitable relief, as well as monetary damages,

to redress Defendants unlawful employment practices and retaliation against Plaintiff,

including Defendant’s unlawful discrimination, harassment and retaliation against Plaintiff

because of his race/color, national origin and religion and because of his complaints about such

unlawful discrimination, harassment and retaliation in violation of Title VII of the Civl Rights

Act of 1964, as amended, 42 U.S.C. § 2000e et seq.;Section 1981 of the Civil Rights Act of

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Case 1:15-cv-07513-RMB-AMD Document 1 Filed 10/15/15 Page 1 of 12 PageID: 1

1866, 42 U.S.C. § 1981 (“Section 1981”); to remedy acts of employment discrimination

perpetrated against him by WAWA (hereinafter “Defendants”).

I. JURISDICTION

2. This Court has jurisdiction over the subject matter of this civil action pursuant to Title VII of

the Civil Rights Act of 1964, 42 U.S.C. § 2000e-16 and Section 1981. The jurisdiction of this

Court is invoked to secure protection of and redress deprivation of rights guaranteed by federal

law which provides for injunctive relief and other relief against discrimination in employment

practices.

3. Liquidated damages, compensatory and punitive damages are available and sought under the

pendant claims.

4. Costs and attorney’s fees may be awarded pursuant to 29 U.S.C.A. § 216(b) and Fed. R. Civ. P.

54.

!II. VENUE

5. This action properly lies in the District of New Jersey pursuant to 28 U.S.C.A. §1391 (b),

because the claim arose in this judicial district.

III. PARTIES

6. Plaintiff, Safet Hajra, is a Kosovo immigrant to the United States. Plaintiff is a Muslim. At

all times relevant and until his termination in May 4, 2012, Hajra was employed as a gas

attendant by WAWA at its store # 0982 located at 3 Arney’s Mount Road, Pemberton, New

Jersey. (“Defendant”).

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7. Defendant is a corporation authorized to conduct business in the State of New Jersey with its

principle executive offices located at 260 W. Baltimore Pike, Media, PA 19063. At all

relevant times, Defendant owned, operated and maintained WAWA store # 0982 in Pemberton,

New Jersey. Defendant engages in an industry affecting commerce and employs more than

500 regular employees. At all relevant times, Defendant met the definition of an “employer”

under all applicable statutes.

IV. PROCEDURAL REQUIREMENTS

8. Plaintiff has complied with all statutory prerequisites to filing this action.

9. Plaintiff Hajra filed a charge based on Title VII violations based on national origin, religion

and retaliation with the Equal Employment Opportunity Commission (“EEOC”). On June 2,

2015, the EEOC determined that there was a violation of Title VII rights and concluded that

Respondent’s discharge decision is a pretext to mask retaliatory motive.

10. The EEOC issued a Notice to Sue Letter on August 3, 2015, after Defendants did not agree to

participate in conciliation of the claims.

11. This action has been filed within the 90 days of Plaintiff’s receipt of his right-to-sue letter from

the EEOC.

IV. FACTUAL ALLEGATIONS

12. Plaintiff, Safet Hajra is a hard working Kosovo immigrant to the United States of America who

worked as a gas attendant at WAWA since September 24, 2010.

13. Plaintiff is a conscientious and reliable employee who performs his duties in an exemplary

manner at all times. Plaintiff worked more than one job in order to provide for himself and his

family.

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14. During his third month of working at WAWA, Plaintiff’s work duties were changed to Fuel/

Gas Station Attendant, however his title remained customer service representative.

15. During his employment with Defendant, Plaintiff was the only employee who was made to

clean toilets, sweep, mop, and clean the store while no other gas station attendant was directed

to do this work. None of the other employees were required to do any of the above duties.

16. Plaintiff was never allowed to order new uniforms despite every other gas station attendant

being allowed to order new uniforms. Plaintiff had to wear used uniforms of ex employees.

17. Plaintiff was paid lower hourly wages compared to other gas attendants. At the time of his

termination Plaintiff earned less hourly wages than other employees. Plaintiff earned $9:25

per hour while other employees, one in particular Peter, was paid $9.75 per hour.

18. On or about April 29, 2012, Plaintiff was told by Elaine Crawford, a new manager at WAWA,

on more than one occasion, that he needed to speak in English as no one understands what he

was saying. This was said in front of other employees and customers.

19. On two other occasions Elaine again told Plaintiff to speak English. Mr. Hajra was surprised

by this comment as he only spoke in English at work and no one ever had a problem

understanding him or speaking to him.

20. No other employee besides Plaintiff was told to speak in English by Elaine.

21. It was only after the third instance that Mr. Hajra advised General Manager, Emmanuel Paul

about Elaine’s comments as it had created a hostile work environment for Mr. Hajra. Mr. Paul

spoke to Elaine who verbally expressed regret about her comment.

!!

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UNLAWFUL RETALIATION COMMITTED AGAINST MR. HAJRA

22. Almost immediately after the “Speak English” incident, on or about May 4, 2012, Patricia

Wallace, Investigator, inquired about missing money from the registers and started questioning

Mr. Hajra. She accused Mr. Hajra of stealing money and harassed him and called him a

criminal and threatened to have him deported. All of this was done under the guise of an

investigatory interview.

23. Mr. Hajra was shocked at the allegations and continued to proclaim his innocence and asked

for the basis of this allegation. Defendant did not show him any proof of the alleged theft.

24. Instead he was questioned for over an hour and was called a “criminal” and threatened

continuously by Wallace with deportation.

25. Plaintiff was discharged from employment after this interview. Defendant then filed a police

complaint and had plaintiff arrested and charged with theft

26. Defendant alleged that Mr. Hajra stole money from the registers based on their observations of

numerous drive offs that had occurred from April 1 - April 28, 2012, the period of time

immediately preceding Mr. Hajra’s complaints about “Speak English”.

27. Defendant alleged that Mr. Hajra performed these drive offs by using a manager’s pin number

which is that individual’s social security number, to access the register and void the sales and

pocketed the money in the amount of approximately $353.00.

28. Mr. Hajra was never provided with the manager’s pin number and he never voided any

transaction.

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29. In fact, Mr. Hajra knows of another employee, Cory, who was given this number but the focus

was only on Mr. Hajra and no one else was questioned. These events were suddenly

discovered only after the ‘Speak English’ incident.

30. There were other employees who were given the number by Mr. Ashton but only Mr. Hajra

was suspected of drive offs and was terminated. In support of the allegations, Defendant

submitted a hand written note to the police from Mr. Ashton indicating that he gave his number

only to Plaintiff.

31. Defendant’s policies prohibit employees from providing their pin number to any other

employee and it is a violation of company policy, yet Mr. Ashton was not discharged and it was

presumed that Mr. Hajra was the wrong doer.

32. Defendant’s policies enforce the repayment of any difference in collections at the end of each

shift. The registers are tallied at the end of every shift separately and the employee is notified

immediately of any discrepancy in their collections. The employees are held accountable for

the difference.

33. In fact, in the past Mr. Hajra has witnessed drive offs at his pump and has paid the difference in

the amounts collected that occurred on his shift. The police were immediately notified as well

when each of these drive offs had occurred.

34. Even while he was being interrogated, Mr. Hajra offered to pay any discrepancy for drive offs

that truly occurred during his shift as long as Defendants provided proof that he was the

responsible employee. However, Defendant failed to give him any details and continued to

harass him in the interview, threatened and discharged him.

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35. The theft charge was a pretext used by Defendant to remove plaintiff in retaliation of his

complaint that he was asked to speak in English.

36. Mr. Hajra was charged with two criminal offenses, one was dismissed and the second one was

downgraded to a Municipal Court offense. This charge was further plead down to violation of

a municipal ordinance.

37. The impact of the police arrest and defending the legal proceedings have caused a financial

and emotional burden causing immense anxiety to Mr. Hajra. Plaintiff has suffered and

continues to suffer on a personal level and at work on account of the false charges and

termination.

38. Mr. Hajra was asked to speak in English on more than one occasion creating a hostile work

environment, and when he complained, he was retaliated against, threatened with deportation,

called a criminal, harassed and terminated. He was then arrested and charged with theft.

39. Mr. Hajra has been discriminated because of his religion and national origin and has been

retaliated against in violation of the law.

V. CAUSES OF ACTION

Count One

(National origin and Religious Discrimination in Violation of Title VII of the Civil Rights Act of 1964, 42 USC § 2000e. et. seq.) !

40. The allegations in the foregoing paragraphs 1 through 39, are re-alleged and incorporated by

reference herein.

41. Defendant has discriminated against the Plaintiff on the basis of his national origin and religion

in violation of Title VII by denying him the same terms and conditions of employment

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available to employees who are not Kosovo Muslims including but not limited to, subjecting

him to disparate working conditions and denying him the opportunity to work in an

employment setting free of unlawful harassment.

42. Defendant has discriminated against Plaintiff on the basis of his national origin and religion in

violation of Title VII by creating, fostering, accepting, ratifying and/or otherwise failing to

prevent or remedy a hostile work environment that included amount other things, sever and

pervasive harassment of Plaintiff because of his race/color and/or national origin and religion.

43. The Defendants’ conduct as alleged at length herein constitutes discrimination based on

national origin and religion in violation of Title VII. The stated reasons for Defendants’

conduct were not true reasons but instead were pretext to hide the Defendants’ discriminatory

animus.

44. Defendant’s unlawful and discriminatory conduct in violation of Title VII was outrageous and

malicious, was intended to injure Plaintiff, and was done with conscious disregard of

Plaintiff’s civil rights, entitling Plaintiff to an award of punitive damages.

!Count Two

(Retaliation in violation of Title VII) !45. The allegations in the foregoing paragraphs 1 through 44, are re-alleged and incorporated by

reference herein.

46. Defendant has retaliated against Plaintiff in violation of Title VII for opposing and/or

complaining of Defendant’s discriminatory practices against himself by inter alia subjecting

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Plaintiff to acts of discrimination and retaliation by firing him from employment and falsely

accusing and charging him with theft and threatening him with deportation.

47. As a direct and proximate result of Defendant’s unlawful and retaliatory conduct in violation of

Title VII, Plaintiff has suffered and continues to suffer sever mental anguish and emotional

distress, including but not limited to depression, humiliation, embarrassment, stress and

anxiety, loss of self-esteem and self-confidence, emotional pain and suffering as well as

physical injury, fro which he is entitled to an award of monetary damages and other relief.

48. Defendant’s unlawful and retaliatory conduct in violation of Title VII was outrageous and



Count Three

(Discrimination and Harassment in Violation of Section 1981)

49. The allegations in the foregoing paragraphs 1 through 48, are re-alleged and incorporated by

reference herein.

50. Defendant has discriminated against Plaintiff on the basis of his national origin and race/color

in violation of Section 1981 by denying him the same terms and conditions of employment

available to employees who are not Kosovo immigrants, including but not limited to,

subjecting him to disparate working conditions and denying him the opportunity to work in an

employment setting free of unlawful harassment.

51. Defendant has discriminated against Plaintiff on the basis of his national origin and race/color

in violation of Section 1981 by creating, fostering, accepting, ratifying and/or otherwise failing

to prevent or to remedy a hostile work environment that included, among other things,

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harassment of Plaintiff because of his national origin and race/color and for wrongfully

terminating him.

52. As a direct and proximate result of Defendant's unlawful and discriminatory conduct in

violation of Section 1981, Plaintiff has suffered and continue to suffer severe mental anguish

and emotional distress, including but not limited to depression, humiliation, embarrassment,

stress and anxiety, loss of self-esteem and self-confidence, emotional pain and suffering, for

which he is entitled to an award of monetary damages and other relief.

53. Defendant's unlawful and discriminatory conduct in violation of Section 1981 was outrageous

and malicious, was intended to injure Plaintiff, and was done with conscious disregard of

Plaintiff's civil rights, entitling Plaintiff to an award of punitive damages.

Count Four

(Retaliation in violation of Section 1981) !54. The allegations in the foregoing paragraphs1 through 53, are re-alleged and incorporated by

reference herein.

55. Defendant has retaliated against Plaintiff in violation of Section 1981 for opposing and/or

complaining of Defendant’s discriminatory practices against himself by inter alia subjecting

Plaintiff to acts of discrimination and retaliation by falsely accusing and charging him with

theft; threatening him with deportation; and by firing him from employment.

56. As a direct and proximate result of Defendant’s unlawful and retaliatory conduct in violation of

Section 1981, Plaintiff has suffered and continues to suffer sever mental anguish and emotional

distress, including but not limited to depression, humiliation, embarrassment, stress and

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anxiety, loss of self-esteem and self-confidence, emotional pain and suffering, for which he is

entitled to an award of monetary damages and other relief.

57. Defendant’s unlawful and retaliatory conduct in violation of Section 1981 was outrageous and



VI. PRAYER FOR RELIEF

58. WHEREFORE, Plaintiff Safet Hajra prays that this Court enter judgment in his favor and

against Defendant, containing the following relief:

a. Declare the Defendants’ conduct to be in violation of plaintiff’s rights;

b. An injunction and order permanently restraining Defendants from engaging in such unlawful

conduct;

c. An award of damages in an amount to be determined at trial, plus prejudgment interest, to

compensate Plaintiff for all monetary and/or economic harm;

d. An award of damages in an amount to be determined at trial, plus prejudgment interest, to

compensate Plaintiff for harm to his professional and personal reputations and loss of career

fulfillment;

e. An award of damages in an amount to be determined at trial, plus prejudgment interest, to

compensate Plaintiff for all non-monetary and/or compensatory harm, including but not limited to,

compensation for his mental anguish, humiliation, embarrassment, stress and anxiety, emotional

pain and suffering, emotional distress;

f. An award of damages for any and all other monetary and/or non-monetary losses suffered by

Plaintiff in an amount to be determined at trial, plus prejudgment interest;

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g. An award of punitive damages;

h. An award of costs that Plaintiff has incurred in this action, as well as Plaintiff's reasonable

attorneys' fees to the fullest extent permitted by law; and

i. Such other and further relief as the Court may deem just and proper.

!LAW OFFICES OF SWATI M. KOTHARI, LLC !!

Dated: October 14, 2015 BY: /s/ Swati M. Kothari Swati M. Kothari, Esq. Attorney for Plaintiff

!JURY DEMAND

Plaintiff hereby demands a trial by jury of all issues of fact.

!LAW OFFICES OF SWATI M. KOTHARI, LLC !

Dated: October 14, 2015 BY: /s/ Swati M. Kothari Swati M. Kothari, Esq. Attorney for Plaintiff !!!!

! 12


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(b) County of Residence.��)RU�HDFK�FLYLO�FDVH�ILOHG��H[FHSW�8�6��SODLQWLII�FDVHV��HQWHU�WKH�QDPH�RI�WKH�FRXQW\�ZKHUH�WKH�ILUVW�OLVWHG�SODLQWLII�UHVLGHV�DW�WKH�WLPH�RI�ILOLQJ��,Q�8�6��SODLQWLII�FDVHV��HQWHU�WKH�QDPH�RI�WKH�FRXQW\�LQ�ZKLFK�WKH�ILUVW�OLVWHG�GHIHQGDQW�UHVLGHV�DW�WKH�WLPH�RI�ILOLQJ��127(��,Q�ODQG�FRQGHPQDWLRQ�FDVHV��WKH�FRXQW\�RI�UHVLGHQFH�RI�WKH��GHIHQGDQW��LV�WKH�ORFDWLRQ�RI�WKH�WUDFW�RI�ODQG�LQYROYHG��

(c) Attorneys.��(QWHU�WKH�ILUP�QDPH��DGGUHVV��WHOHSKRQH�QXPEHU��DQG�DWWRUQH\�RI�UHFRUG��,I�WKHUH�DUH�VHYHUDO�DWWRUQH\V��OLVW�WKHP�RQ�DQ�DWWDFKPHQW��QRWLQJLQ�WKLV�VHFWLRQ��VHH�DWWDFKPHQW��

II. Jurisdiction.��7KH�EDVLV�RI�MXULVGLFWLRQ�LV�VHW�IRUWK�XQGHU�5XOH��D��)�5�&Y�3��ZKLFK�UHTXLUHV�WKDW�MXULVGLFWLRQV�EH�VKRZQ�LQ�SOHDGLQJV��3ODFH�DQ��;��LQ�RQH�RI�WKH�ER[HV��,I�WKHUH�LV�PRUH�WKDQ�RQH�EDVLV�RI�MXULVGLFWLRQ��SUHFHGHQFH�LV�JLYHQ�LQ�WKH�RUGHU�VKRZQ�EHORZ�8QLWHG�6WDWHV�SODLQWLII��-XULVGLFWLRQ�EDVHG�RQ��8�6�&��DQG��6XLWV�E\�DJHQFLHV�DQG�RIILFHUV�RI�WKH�8QLWHG�6WDWHV�DUH�LQFOXGHG�KHUH�8QLWHG�6WDWHV�GHIHQGDQW��:KHQ�WKH�SODLQWLII�LV�VXLQJ�WKH�8QLWHG�6WDWHV��LWV�RIILFHUV�RU�DJHQFLHV��SODFH�DQ��;��LQ�WKLV�ER[�)HGHUDO�TXHVWLRQ��7KLV�UHIHUV�WR�VXLWV�XQGHU��8�6�&��ZKHUH�MXULVGLFWLRQ�DULVHV�XQGHU�WKH�&RQVWLWXWLRQ�RI�WKH�8QLWHG�6WDWHV��DQ�DPHQGPHQW�WR�WKH�&RQVWLWXWLRQ��DQ�DFW�RI�&RQJUHVV�RU�D�WUHDW\�RI�WKH�8QLWHG�6WDWHV��,Q�FDVHV�ZKHUH�WKH�8�6��LV�D�SDUW\��WKH�8�6��SODLQWLII�RU�GHIHQGDQW�FRGH�WDNHV�SUHFHGHQFH��DQG�ER[��RU��VKRXOG�EH�PDUNHG�'LYHUVLW\�RI�FLWL]HQVKLS��7KLV�UHIHUV�WR�VXLWV�XQGHU��8�6�&��ZKHUH�SDUWLHV�DUH�FLWL]HQV�RI�GLIIHUHQW�VWDWHV��:KHQ�%R[��LV�FKHFNHG��WKH�FLWL]HQVKLS�RI�WKH�GLIIHUHQW�SDUWLHV�PXVW�EH�FKHFNHG. �6HH�6HFWLRQ�,,,�EHORZ; NOTE: federal question actions take precedence over diversity cases.�

III. Residence (citizenship) of Principal Parties.��7KLV�VHFWLRQ�RI�WKH�-6��LV�WR�EH�FRPSOHWHG�LI�GLYHUVLW\�RI�FLWL]HQVKLS�ZDV�LQGLFDWHG�DERYH��0DUN�WKLVVHFWLRQ�IRU�HDFK�SULQFLSDO�SDUW\�

IV. Nature of Suit.��3ODFH�DQ��;��LQ�WKH�DSSURSULDWH�ER[��,I�WKH�QDWXUH�RI�VXLW�FDQQRW�EH�GHWHUPLQHG��EH�VXUH�WKH�FDXVH�RI�DFWLRQ��LQ�6HFWLRQ�9,�EHORZ��LV�VXIILFLHQW�WR�HQDEOH�WKH�GHSXW\�FOHUN�RU�WKH�VWDWLVWLFDO�FOHUN�V��LQ�WKH�$GPLQLVWUDWLYH�2IILFH�WR�GHWHUPLQH�WKH�QDWXUH�RI�VXLW��,I�WKH�FDXVH�ILWV�PRUH�WKDQ�RQH�QDWXUH�RI�VXLW��VHOHFW�WKH�PRVW�GHILQLWLYH�

V. Origin.��3ODFH�DQ��;��LQ�RQH�RI�WKH�VL[�ER[HV�2ULJLQDO�3URFHHGLQJV��&DVHV�ZKLFK�RULJLQDWH�LQ�WKH�8QLWHG�6WDWHV�GLVWULFW�FRXUWV�5HPRYHG�IURP�6WDWH�&RXUW��3URFHHGLQJV�LQLWLDWHG�LQ�VWDWH�FRXUWV�PD\�EH�UHPRYHG�WR�WKH�GLVWULFW�FRXUWV�XQGHU�7LWOH��8�6�&��6HFWLRQ��:KHQ�WKH�SHWLWLRQ�IRU�UHPRYDO�LV�JUDQWHG��FKHFN�WKLV�ER[�5HPDQGHG�IURP�$SSHOODWH�&RXUW��&KHFN�WKLV�ER[�IRU�FDVHV�UHPDQGHG�WR�WKH�GLVWULFW�FRXUW�IRU�IXUWKHU�DFWLRQ��8VH�WKH�GDWH�RI�UHPDQG�DV�WKH�ILOLQJ�GDWH�5HLQVWDWHG�RU�5HRSHQHG��&KHFN�WKLV�ER[�IRU�FDVHV�UHLQVWDWHG�RU�UHRSHQHG�LQ�WKH�GLVWULFW�FRXUW��8VH�WKH�UHRSHQLQJ�GDWH�DV�WKH�ILOLQJ�GDWH�7UDQVIHUUHG�IURP�$QRWKHU�'LVWULFW��)RU�FDVHV�WUDQVIHUUHG�XQGHU�7LWOH��8�6�&��6HFWLRQ��D��'R�QRW�XVH�WKLV�IRU�ZLWKLQ�GLVWULFW�WUDQVIHUV�RU�PXOWLGLVWULFW�OLWLJDWLRQ�WUDQVIHUV�0XOWLGLVWULFW�/LWLJDWLRQ��&KHFN�WKLV�ER[�ZKHQ�D�PXOWLGLVWULFW�FDVH�LV�WUDQVIHUUHG�LQWR�WKH�GLVWULFW�XQGHU�DXWKRULW\�RI�7LWOH��8�6�&��6HFWLRQ��:KHQ�WKLV�ER[�LV�FKHFNHG��GR�QRW�FKHFN��DERYH�

VI. Cause of Action.��5HSRUW�WKH�FLYLO�VWDWXWH�GLUHFWO\�UHODWHG�WR�WKH�FDXVH�RI�DFWLRQ�DQG�JLYH�D�EULHI�GHVFULSWLRQ�RI�WKH�FDXVH��Do not cite jurisdictional statutes unless diversity. �([DPSOH��8�6��&LYLO�6WDWXWH��86&��%ULHI�'HVFULSWLRQ��8QDXWKRUL]HG�UHFHSWLRQ�RI�FDEOH�VHUYLFH

VII. Requested in Complaint.��&ODVV�$FWLRQ��3ODFH�DQ��;��LQ�WKLV�ER[�LI�\RX�DUH�ILOLQJ�D�FODVV�DFWLRQ�XQGHU�5XOH��)�5�&Y�3�'HPDQG��,Q�WKLV�VSDFH�HQWHU�WKH�DFWXDO�GROODU�DPRXQW�EHLQJ�GHPDQGHG�RU�LQGLFDWH�RWKHU�GHPDQG��VXFK�DV�D�SUHOLPLQDU\�LQMXQFWLRQ�-XU\�'HPDQG��&KHFN�WKH�DSSURSULDWH�ER[�WR�LQGLFDWH�ZKHWKHU�RU�QRW�D�MXU\�LV�EHLQJ�GHPDQGHG�

VIII. Related Cases.��7KLV�VHFWLRQ�RI�WKH�-6��LV�XVHG�WR�UHIHUHQFH�UHODWHG�SHQGLQJ�FDVHV��LI�DQ\��,I�WKHUH�DUH�UHODWHG�SHQGLQJ�FDVHV��LQVHUW�WKH�GRFNHW�QXPEHUV�DQG�WKH�FRUUHVSRQGLQJ�MXGJH�QDPHV�IRU�VXFK�FDVHV�

Date and Attorney Signature.��'DWH�DQG�VLJQ�WKH�FLYLO�FRYHU�VKHHW�

Case 1:15-cv-07513-RMB-AMD Document 1-1 Filed 10/15/15 Page 2 of 2 PageID: 14

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Law Offices of Swati M. Kothari, LLC Swati M. Kothari, Esq ...€¦ · Swati M. Kothari, Esq. 712 East Main Street, Suite 2A Moorestown, New Jersey 08057 (856) 359-6699 Attorneys